Case 15-16885-LMI
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UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
www.flsb.uscourts.gov
In re:
Chapter 11 Cases
ADINATH CORP., et al.,1
Case No. 15-16885-LMI
Jointly Administered
Debtors.
__________________________________/
DEBTORS’ NOTICE OF FILING (I) CLASS 3 (GENERAL
UNSECURED CLAIM) BALLOT FOR ACCEPTING OR REJECTING PLAN
PROPONENTS’ FIRST AMENDED PLAN OF LIQUIDATION PURSUANT TO
CHAPTER 11 OF THE BANKRUPTCY CODE; AND (II) SOLICITATION LETTER
Adinath Corp. and SFS, Ltd. (collectively, the “Debtors”), by and through their
undersigned counsel, hereby file the attached (i) Class 3 (General Unsecured Claim) Ballot for
Accepting or Rejecting Plan Proponents’ First Amended Plan of Liquidation Pursuant to
Chapter 11 of the Bankruptcy Code; and (ii) the Creditors’ Committee Solicitation Letter2, which
represent revised, clean versions of Exhibits “B” and “C”, respectively, to the Expedited Motion
1
The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are
Adinath Corp. (4843) and SFS, Ltd. (n/k/a Simply Fashion Stores, Ltd.) (6230). The address for the Debtors is
2110 N.W. 95th Avenue, Miami, FL 33172.
2
Capitalized terms used but not defined herein shall have the meanings ascribed in the Debtors’ Expedited Motion
for Entry of an Order (I) Conditionally Approving the Disclosure Statement; (II) Approving the Class [3] Ballot;
(III) Approving the Official Committee of Unsecured Creditors’ Solicitation Plan; (IV) Setting a Date for a
Consolidated Hearing on (A) Final Approval of the Disclosure Statement and (B) Confirmation of the
Liquidating Plan; (V) Establishing and Consolidating the Deadlines to File (A) Objections to the Disclosure
Statement and (B) Objections to Confirmation of the Liquidating Plan; (VI) Approving the Procedures for
Solicitation and Tabulation of Votes on the Plan; (VII) Setting Various Deadlines; and (VIII) Describing Plan
Proponents’ Obligations [ECF No. 797] (the “Expedited Motion”).
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(as defined in footnote 2 herein) filed on April 8, 2016 [ECF No. 797].
Dated: May 5, 2016
Respectfully submitted,
BERGER SINGERMAN LLP
Counsel for the Debtors and Debtors in
Possession
1450 Brickell Avenue, Ste. 1900
Miami, FL 33131
Telephone: (305) 755-9500
Facsimile: (305) 714-4340
By:
2
7115674-1
/s/ Christopher A. Jarvinen
Christopher A. Jarvinen
Florida Bar No. 21745
[email protected]
Paul Steven Singerman
Florida Bar No. 378860
[email protected]
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(Form of Class 3 Ballot (“General Unsecured Claims”))
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UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
www.flsb.uscourts.gov
In re:
Chapter 11 Cases
ADINATH CORP., et al.,1
Case No. 15-16885-LMI
(Jointly Administered)
Debtors.
________________________________________/
BALLOT AND DEADLINE FOR FILING BALLOT
ACCEPTING OR REJECTING PLAN PROPONENTS’ FIRST AMENDED PLAN
OF LIQUIDATION PURSUANT TO CHAPTER 11 OF THE BANKRUPTCY CODE
TO HAVE YOUR VOTE COUNT YOU MUST COMPLETE AND
RETURN THIS BALLOT BY THE DEADLINE
INDICATED BELOW [AS SET PURSUANT TO LOCAL RULE 3018-1(B)]
The Plan Proponents’ First Amended Plan of Liquidation Pursuant to Chapter 11 of the
Bankruptcy Code filed by Adinath Corp. and SFS, Ltd. (f/k/a Simply Fashion Stores, Ltd.)
(collectively, the “Debtors”) and the Official Committee of Unsecured Creditors (the “Creditors
Committee” and together with the Debtors, collectively, the “Plan Proponents”) and dated May
3, 2016 [ECF No. [836] (the “Plan”) can be confirmed by the court and thereby made binding
on you if it is accepted by the holders of two-thirds in amount and more than one-half in number
of claims in each class and the holders of two-thirds in amount of equity security interests in
each class voting on the Plan. In the event the requisite acceptances are not obtained, the court
may nevertheless confirm the Plan if the court finds that the Plan accords fair and equitable
treatment to the class rejecting it.
This ballot is for creditor (insert name) _______________________________________
for the following type of
claim placed in the indicated class in the indicated amount:
1
The Debtors in these cases, along with the addresses and last four digits of each Debtor’s federal tax
identification number are Adinath Corp (4843) and SFS, Ltd. (f/k/a Simply Fashion Stores, Ltd.) (6230). The
address of the Debtors is 2110 N.W. 95th Avenue, Miami FL 33172.
LF-33 (rev. 10/10/14)
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TYPE OF CLAIM
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CLASS IN PLAN
 General Unsecured Claim
The undersigned [Check One Box]
Class 3
 Accepts
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AMOUNT OF CLAIM
$
 Rejects
the Plan of the above-named Debtors.
Signed:
___________________________________________________________
Print Name:
___________________________________________________________
Address:
___________________________________________________________
Phone:
___________________________________________________________
Date:
___________________________________________________________
FILE THIS BALLOT ON OR BEFORE JUNE 9, 2016 at 4:00 p.m. 
with: Clerk of Bankruptcy Court
◙ 301 N. Miami Ave., Room 150, Miami, FL 33128
 299 E. Broward Blvd., Room 112, Ft. Lauderdale, FL 33301
 1515 North Flagler Drive, Room 801, West Palm Beach, FL 33401
If you have more than one type of claim against either of the debtors, separate
ballots must be filed and you should receive a ballot for each type of claim
eligible to vote. Contact the Plan Proponents regarding incorrect or insufficient
ballot(s).
LF-33 (rev. 10/10/14)
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(Creditors’ Committee Letter in Support of Plan Confirmation)
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May 3, 2016
Holders of Class 3 (General Unsecured) Claims Against Adinath Corp. and Simply Fashion
Stores, Ltd. (n/k/a SFS, Ltd.)
Re:
Recommendation of Creditors’ Committee in Favor of
Chapter 11 Plan of Liquidation
Dear General Unsecured Creditor:
We are writing to you on behalf of the Official Committee (the “Committee”) of
Unsecured Creditors of Adinath Corp. and Simply Fashion Stores, Ltd. (n/k/a SFS, Ltd.) (the
“Debtors”). The Committee was appointed by the Office of the United States Trustee for the
Southern District of Florida to represent the interests of general unsecured creditors in the
Debtors’ chapter 11 cases.
Copies of the Plan Proponents’ Plan of Liquidation Pursuant to Chapter 11 of the
Bankruptcy Code (the “Plan”)1 and related disclosure statement (the “Disclosure Statement”)
are being distributed to you, along with a ballot with which to cast your vote. The Committee is
a proponent of the Plan, supports the Plan and urges you to vote in favor of the Plan by
so indicating on the enclosed ballot.
The Disclosure Statement contains extensive information with respect to the Plan and
we encourage you to carefully review it. The Committee urges you to read the Plan and the
Disclosure Statement carefully before you cast a vote(s) to accept or reject the Plan and
to consult with an attorney to the extent you deem that necessary.
The Debtors filed bankruptcy petitions on April 16, 2015. Since its appointment on April
22, 2015, the Committee has taken an active role in the Debtors’ bankruptcy cases since the
Petition Date, including in the liquidation of substantially all of the Debtors’ assets and the
investigation and prosecution of claims for the benefit of the Debtors’ Estates. The Disclosure
Statement includes a full summary of the (i) Debtors’ chapter 11 cases, (ii) projected
recoveries for holders of Allowed General Unsecured Claims, and (iii) terms of the Shah
Settlement (as defined in the Plan) that provides the basis for creditor recoveries under
the Plan.
The Committee believes that acceptance of the Plan is in the best interest of the
holders of Claims and have concluded that the projected recovery represents an
improvement over the recovery, if any, that Class 3 Creditors might expect in a
liquidation under chapter 7 of the Bankruptcy Code or in chapter 11 absent the Shah
Settlement. Accordingly, the Committee recommends that you vote in favor of the Plan by so
indicating on the enclosed ballot.
1
Capitalized terms used but not defined herein shall have the respective meanings ascribed to
them in the Plan. In the event of any conflict between this letter and the Plan, the terms of the Plan shall
control.
Cooley LLP 101 California Street 5th Floor San Francisco, CA 94111-5800
t: (415) 693-2000 f: (415) 693-2222 cooley.com
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In order to count, ballots must be returned by first class mail, overnight courier or hand
delivery to: the Clerk of the Bankruptcy Court, 301 N. Miami Avenue, Room 150, Miami, FL
33128 and be received no later than 4:00 p.m. (prevailing Eastern Time) on June 9, 2016.
Ballots transmitted by facsimile, telecopy, or other means of electronic transmission will not be
counted.
The description in this letter of the terms of the Plan is qualified by and subject to the
discussion and provisions contained in the Plan and Disclosure Statement. The Disclosure
Statement contains extensive information with respect to the Plan that you should review. The
Committee urges you to read the Plan and the Disclosure Statement carefully before you
cast a vote(s) to accept or reject the Plan and to consult with counsel to the extent you
deem that necessary. The Bankruptcy Court hearing on confirmation of the Plan is set for
June 23, 2016 at 10:00 am (prevailing Eastern time).
If you have any questions, please contact the undersigned.
Very truly yours,
Jay R. Indyke, Esq.
Michael A. Klein, Esq.
Robert A. Schatzman, Esq.
Steven J. Solomon, Esq.
Charles M. Berk
Scott Prol
Cooley LLP
Gray Robinson, P.A.
CBIZ MHM, LLC
Lead Counsel for the
Official Committee of
Unsecured Creditors
(212) 479-6000
[email protected]
[email protected]
Local Counsel for the Official
Committee of Unsecured
Creditors
(305) 416-6880
[email protected]
[email protected]
Financial Advisors for the
Official Committee of
Unsecured Creditors
(212) 790-5825
[email protected]
[email protected]
Committee Members
Kevin Ritter, The CIT Group/Commercial Services, Inc. (chairperson)
Robert Olemberg, Olem Shoe Corporation
Anthony Verrilli, Rosenthal & Rosenthal, Inc.
Serkan Ozgun, Louise Paris Ltd.
Abe Hanan, PPI Apparel Group
Cooley LLP 101 California Street 5th Floor San Francisco, CA 94111-5800
t: (415) 693-2000 f: (415) 693-2222 cooley.com
7107034-3